Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Reopening an assessment requires contemporaneous reasons to believe supported by tangible material and a live link to escapement of income; a mere recalculation of full value of consideration using lowest prevailing market value or a change of opinion is insufficient. The taxpayer had already provided stock valuation details and basis in response to queries under section 142(1), and the subsequent communications did not disclose fresh tangible material or a live link justifying reassessment under section 147. The impugned reopening notices were therefore held to lack jurisdiction and were quashed in favour of the assessee.
Reopening an assessment requires contemporaneous reasons to believe supported by tangible material and a live link to escapement of income; a mere recalculation of full value of consideration using lowest prevailing market value or a change of opinion is insufficient. The taxpayer had already provided stock valuation details and basis in response to queries under section 142(1), and the subsequent communications did not disclose fresh tangible material or a live link justifying reassessment under section 147. The impugned reopening notices were therefore held to lack jurisdiction and were quashed in favour of the assessee.
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